ML19343B833

Testimony on Behalf of Util Re Tx Pirg Contentions 2 & 4 & Mccorkle Contention 2 Concerning Cooling Lake Recreational Benefits & Dam Extension

ML19343B833
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	12/18/1980
From:	Schlicht F HOUSTON LIGHTING & POWER CO.
To:
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1 DIRECT TESTIMONY OF DR. FRANK G. SCHLICHT

, ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY RE TEXPIRG CONTENTIONS 2 AND 4 AND MCCORKLE CONTENTION 2 (COOLING LAKE RECREATIONAL BENEFITS AND DAM EXTENSION) i L

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' DIRECT TESTIMONY OF DR. FRANK G. SCELICHT RE COOLING LAKE RECREATIONAL BENEFITS 1

Q. Please state your name and position.

2 My name is Frank G. Schlicht.

A. I am Principal 3

Scientist in the Environmental Protection Department of 4 Houston Lighting & Power Company (HL&P), a post I have 5 held since 1970.

6 Q. Please describe your responsibilities related 7 to Allens Creek Nuclear Generating Station (ACNGS).

8 A. I was responsible for the ecological monitoring 9 programs at the ACNGS site and for the preparation and 10 review of the sections of the Environmental Report that 11 dealt with nonradiological ecological monitoring. I 12 was also responsible for such matters for the South 13 Texas Nuclear Project. In addition, I was responsible 14 for developing the recreational plan for the ACNGS reservior, including plans for fishery habitat improvement 3_a a d park development.

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Q. Please describe your educational background.

A. I h Id a Bachelor of Arts degree in biology 8

from Texas Christian University (1960), a Master of l Science degree in zoology from Texas Agricultural and 20 Mechanical College (1963), and a Doctor of Philosophy 21 degree in marine zoology frem Texas A&M University 22 l

(1969).

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1 Q. What are your professional associations?

2 A. I am a member of the National Shellfisheries 3

Association, the American Fisheries Society, and Sigma 4

Xi (Associate Member).

5 Q. Please state your occupational background 6 before you joined HL&P.

7 A. Before joining HL&P, I was an assistant 3 Marine Biologist, Texas Game and Fish Commission 9 (1958-1959); a Research Assistant, Institute of Marine 10 Science, Port Aransas, Texas (1960); a Research Assistant 1; at Texas A&M University (1960-65); a Graduate Fellow, 12 Texas A&M University (1965-67); an Insrructor of Biology, 13 San Jacinto College, Pasadena, Texas (1967-69), and 4

Chief Biological Oceanographer, Oceanonics, Inc.,

Houston, Texas (1969-70).

l_a Q. Besides your work related to ACNGS, generally describe your responsibilities at HL&P.

7 A. My responsibilities at HL&P include the supervision of research and monitoring programs on thermal discharges at HL&P plants with once-through 20 cooling systems, mariculture associated with once-through 21 cooling systems, effects of salt-water drift from 22 brackish-water cooling towers on terrestrial vegetation, 23 and biofouling in brackish-water cooling towers. I 24

1 have also been responsible for incorporating the findings 2

of these and other studies into the design and operating 3

practices of new and existing power plants in the HL&P 4 system. These applications include, but are not limited i 5 to, intake structure design, biocide selection and 6 application, and impinged organism bypass handling 7 systems.

8 Q. What other responsibilities have you undertaken?

9 A. I have served on the Electric Reliability 10 Council of Texas (ERCOT) ad hoc Water Quality Committee 11 that represented the industry before the Texas Water 12 Quality Board when new state standards were being 13 developed in accord with PL-92-500. I also served on l 74 the Edison Electric Institute (F7I) Water Quality ad g hoc committee that drafted the Ef. comments on the

( 6 PL-92-500 section 316(a) draft guidelines document. I l

was a member of the EEI steering committee for RP-49, a 77 multi-million dollar research project by John Hopkins 3

University on the impingement, entrainment, and thermal discharge effects of once-through cooling systems on i aquatic ecosystems. I have served as a member of the Electric Power Research Institute's Energy Systems,

! 22 l Environmental and Conservation Division, Task Force on 23 Environment, for six years, the last two as vice-chairman.

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1 Q. Have you published any scientific papers?

2 A. I have participated in writing several 3

published papers on oysters, fish, parks, and impinge-4 ment and entrainment.

5 Q. What is the purpose of this testimony?

6 A. The purpose of this testimony is to respond 7 to TexPirg Contentions 2 and 4, and McCorkle Contention 8 4, which state:

9 The smaller cooling lake size and changed location of the lake vis a vis the original 10 proposal will render the lake useless as a viable recreational fishery because:

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a. the changed location eliminates 12 the Bluff area as a recreational and fish spawning area; r 13 l b. the amount of chlorine which l

' ~4 3 will be released to the lake has more than doubled, which will result in significant fish kills; la l c. sewer discharges from Wallis, 6

l Sealy and the nuclear plant will cause an 17 excessive algae growth in the lake;

d. the heavy metal concentrations 13 in the lake will result in heavy metals concentrat-ing in the fish and will make them inedible; 19 and 20 e. thermal shock will kill large numbers of fish during the winter when plant i

21 shutdowns occur.

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22 Even if a cooling lake is approved by the l Board, the Board should require that it be 23 redesigned to be more of an environmental benefit and less of an environmental burden.

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Specifically, the dam (levee) should be extended 2 northward to a point just east of its present northeast corner so that the runoff can go 3 into the lake and so that the north bluff area can be a viable fish spawning area.

4 For convenience, I will generally refer to these l 3 contentions as one contention.

l 6 Q. Are you the only witness for Applicant on l 7 these contentions?

l 8 A. No. I will address general fishery management 9 issues such as the carrying capacity of the lake, l 10 species composition, habitat management, spawning, 11 and so forth. Dr. Lial'F. Tischler, Vice President 12 and Manager of the Austin Office of Engineering-Science, 13 Inc., will testify on water quality issues such as 14 chlorine discharges, sewage discharges, and heavy 3 _2 metal concentration. I will comment briefly on these matters as they relate to the biological issues.

6 17 Q. The contention says the ACNGS reservoir Will be "uselesG as a viable recreational fishery."

Is this true?

19 A. No. The ACNGS cooling reservoir will be a viable recreational fishery. To understand why, it 21 is useful to begin with a review of the history and 22 background of the reservoir.

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1 Q. Please do so.

2 A. When HL&P announced the ACNGS project in 3

1973, the company made a commitment to develop the 4

reservoir as a recreational asset for the public. At 5 that time, the company planned to build two units 6 with about 2,400 megawatts electric (MW(e)) total 7 capacity, and the reservoir was designed to be 8,000 3 acres in surface area. The company set aside land 9 for parks to serve fishermen, swimmers, boaters, 10 campers, picknickers, and other recreationists.

11 HL&P approached the Texas Parks and Wildlife s 12 Department about developing the land as state parks.

13 The Department informally received the proposal l

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favorably, and thereafter HL&P retained Dames & Moore 3

a as consultant to develop a master plan for the parks.

The master plan was previously presented as an exhibit l in this proceeding. (See Applicant's Exhibit No. 5).

7 g This development plan was prepared according to the methods used by the Texas Parks and Wildlife Depart-ment, then submitted to the commissioners of that 20 l

agency with a formal request that the park be developed 21 as a state park. The commissioners approved the plan 22 on May 23, 1974, and further authorized the agen'cy to l 23

) proceed with development.

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1 Q. How did you determine the original reservoir 2

would or would not be a viable recreational fishery?

3 A. A fishery management panel was organized to 4 evaluate the potential of the proposed cooling lake 5 as a recreational fishery and to recommend fishery 6 habitat improvements and a management program. My 7 fellow panel members were Dr. Clark Hubbs, Department 3 of Zoology, University of Texas, Austin; Dr. E. Gus 9 Fruh, Department of Environmental Engineering, University 10 of Texas, Austin; Dr. Kirk Strawn, Department of 11 Wildlife and Fisheries Science, Texas A&M University; 12 Dr. John Kelly, formerly of the Department of Wildlife 73 and Fisheries Sciences, Texas A&M University; and Mr.

Lonnie Peters, former Director of Inland Fisheries, 4

,_ Texas Parks and Wildlife Department. This panel

.o concluded that the proposed reservoir would support a l 7 productive sport fishery based on native species.

The panel also recommended several fishery habitat l improvements, such as leaving as much standing timber as possible, building brush piles near shore, and 20 creating mounds of earth on the lake floor. HL&P 21 agreed to follow these recommendations.

22 Q. Did the licensing board review the viability

! 23 l of the original lake as a fishery?

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A. The Board noted in the Partial Initial 2

Decision of November 11, 1975, that "[t]he parties 3

agree that the reservoir would be a good sports 4 fishery," and that "[o]peration of the ACNGS would 5 not have a significant impact on the aquatic biota 6 of . the reservoir . "

. . . . . (PID at T40, 148).

7 Q. What happened next?

8 A. Subsequently, the original ACNGS project 9 was deferred. When reactivated, the plan called for 10 a single generating unit of 1,200 MWe, with a cooling I

11 reservoir of about 5,000 surface acres. The change 12 in plans and reduction in reservoir size did not 13 alter the plans for development of a state park. It did, however, raise questions whether the smaller 4

,_ reservoir would be a good recreational fishery.

.o Q. Did you re-examine the viability of the 6

7 smaller lake as a recreational fishery?

g A. Yes. To evaluate the fishery potential of the 5,000-acre reservoir, a fishery management panel l consisting of Dr. Hubbs, Dr. Strawn, Dr. Clark, Mr.

Bob Bounds of the Texas Parks and Wildlife Department, t 21

! and myself was convened. HL&P estimated the standing 22 crop for the newly designed reservoir to be 200 23 lb/ acre, the same as the standing crop estimate for 24

t the larger reservoir. No member of the panel disagreed 2

with that estimate. The panel did note, however, 3

that periodic restocking of largemouth black bass

• 4 might be necessary, due to the lack of sufficient 5 shallow spawning areas necessary for that cpecies to 6 maintain its maximum population. The ratio of game 7 fish to rough fish is, however, expected to be the 8 same for the smaller reservoir as was predicted for 9 the larger reservoir. As discussed in the ER 10 (S.5.1.6.1), the ratio in unheated reservoirs is 11 generally 70 percent rough fit.h and 30 percent game 12 fish, but in heated reservoirs it is typically 60 13 percent game fish and 40 percent rough fish. The i

74 latter ratio is expected to apply to the Allens Creek j ,_ reservoir.

.2 Q. Please state your conclusions about the viability of the smaller lake as a recreational 7

fishery.

g A. There is no reason to believe that the 19 population dynamics of the Allens Creek reservoir fishery will be any different from those found in 21

, other heated Texas reservoirs. Moreover, the reduction l 22 in size of the reservoir did not reduce the size of 23 the proposed park or change the development plans for 24 l

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the park. The change in lake size merely reduced the 2

4 expectations for one species of game fish, largemouth 3

black bass, thus changing slightly the character of 4

the fishery, but not its viability.

5 Q. Do these reduced expectations for largemouth 4

6 black bass mean the lake will be " useless as a viable 7 recreational fishery"?

8 A. No. In evaluating the recreational fishery 9 value of the cooling reservoir, one should examine 10 the type of fish the reservoir is best suited to 11 support and then examine the importance, or significance, 12 of this type of fish in the area. By importance, or 13 significance, I refer to the amount of effort expended 14 by fishermen in pursuit of the fish. The Allens 3_a Creek reservoir is expected to provide one of the best crappie (white perch) fisheries in the state.

77 This species does very well in impoundments that have g

brushy shorelines and bottoms, both cf which will be present in the reservoir. The flooded Allens Creek channel and the brushy bluff should provide more than ample spawning habitat for this species and those i species that constitute its main food sources.

22 Allens Creek reservoir is also expected to provide an i 23 excellent fishery for catfish.

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1 Q. How does the crappie compare with the 2

largemouth black bass as a sport fish?

3 A. The number one sport fish in the State of 4 Texas, based on effort spent pursuing the fish, is 5 the crappie. In other words, more fishing days are 6 spent in pursuit of crappie than of any other freshwater 7 species in Texas. It is an extremely popular fish, 8 especially with those who fish from the bank or who 9 are more interested in fish for the table than for 10 wall mountings.

11 The largemouth black bass is also a popular, 12 desirable sportfish, especially with those who would 13 rather land one or two ten-pound fish than twenty pounds of one-pound fish. The reservoir will provide 4

,_ a black bass fishery, but it is not expected to be of

.a the same quality as other reservoirs in the area, such as Lakes Conroe and Livingston.

7 For these reasons, it is my opinion that g

the possible tradeoff--proportionately mere crappie and proportionately fewer black bass--is a favorable one. This is an issue of species preference, not of 21 fishery viability.

22 Q. TexPirg and McCorkle contend that the 23 reservoir, because it is now smaller than first 24

1 planned, will be " useless as a viable recreational 2

fishery" for a variety of reasons. Is this lake too I

3 small to serve as a viable recreational fishery?

4 A. No. In addressing the issue of the lake 5 size, it is prudent to look at the sizes of other 6 reservoirs in the state and the level of recreational 7 usage made of these reservoirs. Applicant's Exhibit 8 No. (FGS 1) lists twelve reservoirs, eleven of 9 which are smaller than the ACNGS reservoir. All of 10 these are heated reservoirs and are open to the ,

11 public for recreational use. Two of these, Lakes 12 Colorado City and Fairfield, have state parks associated 13 with them. Lake Colorado City has been featured g twice by Texas Parks & Wildlife Magazine. (Refs. 1, g 2). Both of these articles emphasized the recre-ational value of Lake Colorado City. All of these g reservoirs are popular recreational water bodies and some are noted for their outstanding production of largemouth black bass. Lakes Calaveras and Braunig l are both used for fishing tournaments. Based on bass club tournament statistics reported to, and analyzed 21 by, the Texas Parks and Wildlife Department, Lake 22 i

Calaveras was "the state's best all-round black basr 23 lake in 1979." (Ref. 3 ) . In sum, the viability of a 24

1 recreational fishery is clearly not determined by 2

size alone. The ACNGS reservoir will be larger than 3

a number of other reservoirs that provide excellent 4 fishing opportunities.

5 Q. The contention states that ACNGS will be 6 " useless as a viable recreational fishery" because 7 the " changed location eliminates the Bluff area as a s

3 recreational and fish spawning area." It further 9 states that the dam should be extended to catch more 10 runoff and to provide "a viable fish spawning area" 11 in the " north bluff area." Does the lack of this dam 12 extension make the reservoir " useless as a viable 13 recreational fishery"?

34 A. No. As I stated above, the reservoir will be a viable fishery without this extersion of the 3_2 dam. The dam extension would only increase the 6

7 fishable area of the reservoir. It would not improve g

the quality of the fishery: that is, the standing crop per acre would remain the same.

Q. How can the potential spawning area be reduced without reducing the size of the standing 21 crop?

22 A. This lake, like every other lake, will have 23 a certain carrying capacity for fish in pounds per 24

1 acre, based on factors such as the availability of 2

food. We have astimated a crop of 200 pounds per 3 acre. This is something of a constant, a biological

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4 limit. Once it is reached, the addition of more fish 5 will only temporarilf increase the crop, because 6 there won't be enough space or food for the newcomers 7 and oldtimers both, and some of them will die, restoring 8 the balance.

9 To sustain this crop will require certain 10 necessary inputs of new fish, either from spawning or 11 restocking, to replace those that die or are caught 12 by fishermen. Once sufficient inputs are present, g3 additional inputs are unnecessary. You can't increase l 74 the yield beyond the biological limits by "overplanting" the crop.

3_s The most important question is whether the 6

77 lake will have sufficient spawning area to provide g the necessary inputs to maintain the standing crop.

The answer is yes. As I stated before, the second

, fishery management panel considered this very matter l 20 l and concluded that the spawning habitat is sufficient l 21 l to maintain the crop. The added spawning area is not 22 l necessary to maintain the fishery.

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1 Crappie, as previously stated, spawn in 2

shallow brushy areas. The lake contains such habitat 3 along the bluff and in Allens Creek. It is my opinion 4 that this habitat is sufficient to maintain a strong 5 crappie population in the lake.

6 Q. Would inundation of the so-called " north 7 bluff area" improve spawning conditions for largemouth 8 black bass?

9 A. Possibly. But let me repeat, this is a 10 matter related to the character of the reservoir as a il recreational fishery, not its viability. For example, 12 the bluff area is generally too steep to provide top 13 quality bass spawning areas. If the slope of the bluff is less to the north than it is in the reservoir, 14 it could provide better spawning sites for bass, l_a This, however, would not necessarily result in a 6

3 significant increase in the overall standing crop of

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g bass in the reservoir. Assuming, though, that it i did, one would expect to see a decline in the standing crop of some other sportfish species that would be equivalent to the increase in standing crop of black 21 bass. As previously stated, the reservoir will 22 contain sufficient spawning habitat to sustain a 23 viable sport fishery. Extension of the dam to include 24 l

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more bluff area in the reservoir shoreline will not improve the quality or viability of the fishery, only 3

its character.

4 Q. If it is later determined that the population 5

of largemouth black bass should be increased, could 6 this be done without extending the dan?

7 A. Yes. If the Texas Parks & Wildlife Department, S which will have authority of such matters, decides to 9 alter the character of the reservoir as a fishery by 10 increasing the population of largemouth black bass 11 relative to other fishes, that can easily be done 12 through stocking of that species. But, as I said 13 earlier, I believe the lake will be more valuable as 14 a self-sustaining crappie fishery--an alternative to 3-2 the other bass fisheries already available.

16 Q. Will the reservoir be " useless as a viable 17 recreational fishery" due to the lack of any runoff 18 that might be collected by the proposed dam extension?

g A. No. The volume of lake water will readily be maintained without any added runoff.

Q. You say the runoff is not necessary to the viability of the lake as a fishery. Would runoff be 22 l desirable? Would it improve the lake as a recreational 23 fishery?

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1 A. I fail to see the point of that portion of 2

the contention relative to additional runoff to the 3

reservoir. Increased runoff certainly does not 4

automatically mean a better fishery. To the contrary, 5

increased runoff can be damaging to a fishery, particularly 6 if the runoff is high in suspended solids and occurs 7 during the spawning season. Under these conditions 3 the year's spawn can be lost or severely impaired due 9 to siltation of nests and the resultant suffocation 90 of eggs and young.

11 To repeat, the reservoir will be a viable fishery 12 without the dam extension. There is no justification 13 for extending the dam, from either the standpoint of l 14 increased spawning area or providing additional l

l 13 runoff to the reservoir.

Q. Turning now to the next issue raised by the 16 17 intervenors: The contention says the lake will be l

" useless as a viable recreational fishery" because 18 g "the amount of chlorine which will be released to the 1

lake has more than doubled and will result in significant fish kills." For background purposes, what is the reason for discharging chlorine?

i A. Chlorine is used to prevent fouling of the 23 condensers by biological organisms, which reduces the 24

efficiency of the cooling system if unchecked.

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Q. The intervenors say the " amount" of chlorine 2

released in the lake "has more than doubled." Is 3 this true?

4 A. No. The amount of chlorine discharged by 5 the single unit at ACNGS is expected to be no more 6 than 1,525 lbs/ day. (FES-FS 3.3.1.1). Two plants 7 would have discharged 2,100 lbs/ day. (FES Table 3 3.10). The amoudt of chlorine discharged has clearly 9 been reduced, not increased, as the contention errone-10 ously states.

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11 In any case, consideration of the amount of 12 chlorine discharged is meaningless without considering 13 other parameters, such as the water volume into i

l which the chlorine is discharged. As noted later in 4

this testimony, this chlorine / volume ratio will be l_a much lower at ACNGS than at another HL&P reservoir, 1

where there is no evidence of fish kills.

7 Q. How will chlorination practices at ACNGS compare with standard chlorination procedures at HL&P?

i 20 A. The fact that chlorination will be limited  !

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to two 15-minute periods per day is, in itself, a 22 l departure from standard chlorination practice at most 23 other plants in the HL&P system, where the units are 24 t

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t chlorinated three times a day for approximately 20 2

minutes per period. The chlorination program for 3

Allens Creek thus represents a 33-1/3 percent reduction 4

from the norm in frequency and a 25 percent reduction 5 in duration, each of which, independently, would be 6 expected to reduce the already low risk of fish kills t

7 by chlorination at ACNGS, compared to other HL&P S plants. Furthermore, the W. A. Parish Plant has

9 discharged as much as 900 lbs/ day into a cooling lake

10 of 2,475 acres with no evidence of fish kills. To I

11 put this into perspective, we discharge as'much as l

l 12 900 pounds of chlorine a day into approximately 13 10,000 acre feet of water at the W. A. Parish Plant 14 without harm. We are proposing to discharge a maximum l'3 f 1,525 lbs/ day into 81,000 acre feet at Allens 6

Creek. In other words, we are presently discharging 17 '4.5 times as much chlorine per acre foot of water at 18 the Parish station as we are proposing to discharge l

at Allens Creek.

9 Q. Will the discharge of chlorine by ACNGS kill significant numbers of fish in the cooling reservoir?

22 A. No. But let me refer you to the testimony 23 of Dr. Lial Tischler on the general issue of the 24 toxicity of chlorine concentrations in the ACNGS 2

reservoir. He exhaustively reviews the issue and 3

concludes that the chlorine discharges will not 4

generally be toxic to aquatic biota, except in a 5 relatively small area within 1,200 to 1,500 feet of 6 the point of discharge, which fish will generally 7 avoid during chlorination. Furthermore, he finds no 3 reports of fish kills in similar cooling lakes around 9 Texas.

10 Q. Do you agree with his conclusions?

11 A. Yes. I can only add to his testimony that 12 I have neither seen a reference to, nor heard of, a

.I 13 chlorine-related fish kill at a power plant involving 14 warmwater fishes--the group that includes largemouth 9_2 bass, sunfishes, crappie and catfishes. The reported fish kills associated with powerplant chlorination 6

77 that I am aware of were confined to the Great Lakes g region and involved coldwater fish species, largely vaa'ious trout species. Brungs (1977) stated, "The g

present published literature contains many data that force the conclusion that trout and salmon are more 21 sensitive to total residual chlorine than are the 22 warmwater species." (Ref. 4). As previously stated, 23 the Allens Creek reservoir will be populated by 24

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warmwater species, which generally are not as sensitive 2

to chlorine as are their coldwater counterparts.

3 Q. Are many fish likely to be or remain in the 4 possible danger zone during chlorine discharges?

l 5 A. No. Fish are mobile. Based on my reviews 6 of the literature, it is my opinion that all but the j 7 weakest are likely to avoid areas where the chlorine 1'

3 concentration might be lethal. They will simply swim 9 away. Exposure of eggs, larvae, and fry, the weakest 10 stages, will largely be restricted to those individuals 11 entrained through the condensers, as most species are 12 expected to spawn in areas of the lake other than the 13 discharge canal. Therefore, losses to these age 14 groups will be minimal and have no significant effect on the populations as a whole.

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Q. How many operating HL&P powerplants are l

l 17 already equipped to clean condensers with chlorine?

7g A. Six, including W. A. Parish, which I mentioned previously.

g l Q. Has any fish kill ever occurred at any of these plants, to your knowledge, as a result of chlorination.

22 A. No.

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l Q. You emphasize the low rate of chlorination now planned at ACNGS. Can this rate be lowered even I 3 further when the plant begins actual operations?

4 A. Quite possibly, it can. Because the optimal 5 frequency, duration and concentration of chlorination 6 are site specific and cannot be accurately predicted 7 -

prior to actual plant operation, wr&P has committed 3 to a chlorine minimization study at ACNGS. The 9 details of the study have not been developed at this 10 time, but it would be comparable to similar studies -

11 elsewhere. The first step will be to establish the 12 condenser efficiency baseline. The next phase will 13 be to determine the minimum frequency, duration, and 14 concentration of chlorination that will keep the g3 condenser clean and maintain condenser. heat exchange 16 effi ien y. The sequence in which tl'.ese aspects are 17 studied is of no consequence. The critical factor is that the studies should be conducted during the g season (s) when biofouling is most apt to cause a problem, which are spring, summer and early fall.

Q. Please be more specific and describe how such a study might be conducted.

22 i- A. A typical minimization study protocol might 23 be to first reduce the chlorination frequency until 24

I condenser efficiency begins to decline. This step 2

could reveal that chlorination is not needed. However, 3

if the need for chlorination is clearly indicated.

4 the second step might be to determine the atinimr.m l 5 duration required to maintain condenser efficiency.

6 The next phase might be to reduce the concentration 7 to the lowest possible level that still maintains 8 efficiency. The last phase in this scenario would 9 then be to determine the optimal frequency. For 10 example, four 5-minute clorination periods per day 11 may be more efficient than two 15-minute periods.

12 Q. How long would the HL&P chlorine minimiza-i 13 tion study continue?

g4 A. Because fouling can be a more serious 3

2 problem some years than others, once a minimal program has been selected it should be tested for at least 6

one full year, and preferably longer, before a final 17 18 mmitment is made to continue that program permanently.

This is imperative in view of the seasonal changes in fouling rate, water temperature and chemistry, and chlorine demand of the water. All of these conditions 21 vary seasonally and between years. Therefore, a 22 single year of study would not necessarily be repre-23 sentative of the long term, or average, situation.

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1 Q. In conclusion, what is your professional 2

opinion about the impact of chlorine discharges on 3 the viability of the ACNGS reservoir as a recreational 4 fishery.

l t 5 A. Based on experience at existing plants in 6 the HL&P system and other utilities in the state, on 7 Dr. Tischler's testimony, and on the extant literature, 8 it is my opinion that any fish losses due to chlorina-9 tion will be minimal, and further, that these losses 10 will not have a measurable effect on,the fish populations 11 of the ACNGS reservoir. Chlorine discharges certainly 12 will not make the lake useless as a viable recreational 13 fishery.

l 14 Q. The contention states that ACNGS will be i

,_ " useless as a viable recreational fishery" because l .2

" sewer discharges from Wallis, Sealy and the nuclear 6

plant will cause excessive algae growth in the lake."

77 Is this allegation true?

g A. No. I refer you again to the testimony of l Dr. Tischler. He studied the potential for nutrient

! 20 l enrichment of the ACNGS reservoir and compared this 21 potential with nutrient enrichment of several other 22 heated reservoirs in Texas and one in Illinois. He 23 has addressed fishery productivity in the reservoir i 24

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1 and concluded that Allen's Creek Reservoir will be "a 2

valuable recreational resource in terms of both 3 fishing and contact recreation."

4 Q. Do you agree wid2 his findings?

t 5 A. Yes. I can add only that I know of no 6 instance in the HL&P system or elsewhere when any 7 heated reservoir has experienced nuisance algal 8 blooms that restricted recreational use.

9 Q. In particular, do yot know of any comparable 10 Texas lakes that are useless as viable recreational 11 fisheries because of sewage discharges?

12 A. No. It is noteworthy that Lakes Calaveras, 13 Brannig, and Trinidad all receive nutrient-enriched 14 make-up water. Lakes Calaveras and Braunig get g make-up water from the San Antonio River downstream of the municipal waste treatment facilities for the 7

city of San Antonio, which is somewhat larger than g

Sealy. Make-up water for Lake Trinidad is pumped from the Trinity River downstream of the Dallas-Fort l Worth area. The Trinity River receives the municipal l 20 waste treatment effluents from this large metroplex.

21 In spite of the high nutrient loadings of these three reservoirs, there have never been any reported cases 23 -

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1 of nuisance' algal blooms that have restricted recrea-2 tional activity. In fact, I have found no evidence 3

of nuisance algal blooms of any magnitude having 4

occurred on any of these, or other, heated reservoirs t 5 in the state of Texas.

6 Q. This is a heated reservoir. Will the heat 7 discharges interact with nutrient loads to make algal 8 blooms more severe or more common?

9 A. Let me answer that by pointing to two 10 relevant studies. In a recently published study done 11 by Battelle, Pacific Northwest Laboratories (1979) 12 (Ref. 5 ), it was reported that the phytoplankton l 13 responses to elevated temperatures appeared only near 14 effluent outfalls, which represented restricted 32 portions of each cooling reservoir. Five of the nine heated reservoirs in their study are in Texas--Lakes 6

77 Braunig, Calaveras, Fairfield, Arlington, and Trading l

l , House Creek. Price (1974) reported on the phytoplankton

, .8 l populations in three heated and two unheated reservoirs l

19 in Texas. He stated that "[a]ny differences between

' and within heated and unheated reservoirs . . .

21 cannot be validly ascribed to differences in the .nal 22 l loading." (Ref. 6).

23 Q. What is your conclusion about the effect of 24 sewage discharges into the lake?

l i

1 A. Sewage discharges will not affect the 2

viability of the reservoir as a recreational fishery.

3 Q. Another part of the contention says the 4 ACNGS reservoir "will be useless as a viable recreational 5 facility" because " heavy metal concentrations in the 6 lake will result in heavy metals concentrating in the 7 fish and will make them inedible." Is this true?

3 A. No. This contention cannot be substantiated.

9 Dr. Tischler testifies that heavy metal concentra-10 tions in the Allen's Creek reservoir will not be any

~

11 greater than similar accumulations in other reservoirs in Texas, both heated and unheated. He further 12 13 testifies that he can find no evidence of observed l problems with the accumulation of heavy metals in i 14 cooling lakes.

g Q. Will the ACNGS reservoir meet Environmental g Protection Agency standards on heavy metals?

A. Yes. As pointed out by Dames and Moore (1978) in their study of heavy metals in the Brazos River for HI4P, the concentrations of the metals 20 which they analyzed were all well below the EPA 21 recommended maximum concentrations. Dames and Moore 22 concluded, "It is, therefore, reasonable to conclude 23 that no detrimental impact on the recreational potential 24

1 of the Allen's Creek Lake, due to bioaccumulation, 2

will occur." (Ref. 7). But, again, let me refer you 3

to Dr. Tischler for more detailed analysis.

4 Q. Will HL&P sample the fish population and 5 test for heavy metals after the lake is built?

6 A. Yes. To account for the remote possibility 7 that heavy metals may enter the reservoir from an 8 unexpected source, EL&P has agreed to conduct such 9 monitoring. (S. 6.1-2).

10 Q. Finally, the contention states that the 11 lake "will be useless as a viable recreational fishery" 12 because " thermal shock will kill large numbers of 13 fish during the winter when plant shutdowns occur."

14 To your knowledge, has cold shock from a powerplant ,

shutdown ever killed any fish in Texas?

73 A. No. I know of no cases of this problem 6

occurring at any of the powerplants in the state of 7

Texas. All instances of cold shock fish kills known to me involving native fish have occurred in colder recions of the United States.

20 Q. What causes cold shock mortality in fish?

21 A. The instances of cold shock kills that I am 22 familiar with have not been due to the rate of change 23 of discharge temperature; instead, they were due to 24

1 the fact that the ultimate temperature reached was 2

below the tolerance level for certain species of 3

fishes. For example, the Oyster Creek Nuclear Power 4

Plant of Jersey Central Power and Light Company 5 experienced a series of fish kills associated with 6 winter shutdowns of the unit in the early seventies.

7 The species involved (Atlantic Menhaden) is a warmwater i

! 8 species that normally migrates'from the area each 9 fall. The warm discharge waters attracted an overwinter-10 ing population of this species, however. Apparently l in every instance when a kill was noted at this 11 12 plant, the ambient temperature at the time was below 13 the lower thermal limit of the species, and the kill 14 did not occur until after the temperature in the g3 discharge area had fallen below the lower tolerance l 6 limit of the species. (Ref. 8). Young (1974),

1 17 addressing cold shock fish kills at powerplants, I

g stated: " Cold shock,-the converse of heat shock, may occur when organisms living at a relatively high temperature are suddenly exposed to one much lower, usually near or below their minimum thermal tolerance."

(Ref. 8). This view is further supported by the fact 22 that there are no reported " cold shock" kills associated 23 l with plant shutdown during the warmer months of the 24

1 year. If this phenomenon were truly one of " shock"--

2 i.e., rapid rate of change-~ kills should occur any 3 time a unit is shut down, as the rate at which the 4 discharge temperature drops is a function of system 5 operation prior to shutdown rather than of prevailing 6 water temperature at the time of shutdown. Moreover, 7 I know of no overriding circumstances that would 3 cause cold weather shutdown procedures to be any 9 different than warm weather shutdown procedures.

10 Q. What does this principle mean when applied 11 to thermal applications in Texas and specifically at 12 ACNGS?

13 A. There are no seasonally migratory fishes 3

4 native to the freshwaters of the state of Texas. All native species are able to withstand the lowest 3 _2 natural temperatures that the waters of the state attain. EL&P will not artificially reduce the water 7

temperature of the ACNGS reservoir below naturally 3

induced temperatures. Therefore, it will be impossible to have water temperatures in the reservoir below the lower tolerance level of the fish species inhabiting 21 the reservoir.

22 Q. What do you conclude from your analysis?

23 l

l 24

T

~

A. One can reasonably conclude from the foregoing 2

that there is little, if any, likelihood that cold 3

shock kills will occur when the ACNGS unit is shut 4 down in the winter.

5 Q. To sum up, the contention says the size and 6 location of the lake, the elimination of the " north 7 bluff area," chlorine discharges, algal growth, heavy l 8 metals concentration, and thermal shock will make the 9 ACNGS reservoir useless as a viable recreational f

10 fishery. Taking all of these matters into considera-1 l

11 tion and applying your professional expertise, do you

12 now state that ACNGS will provide a viable recreational

fishery? .

A. Yes.

74 13 16 l 17 l

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20 21 22 23 1 I

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c 1

APPLICANT EXHIBIT NO. (FGS-1)

! 2 3

TABLE I 4 Sizes of Some Typical Heated Texas Reservoirs i 5 Name Size (Surface Acres) 6 Alcoa 800 l 7 Arlington 2200 l 8 Bastrop 906 9 Braunig 1340 10 Calaveras 3550 11 Colorado City 1612 92 Eagle Mountain 8500 13 Fairfield 2350

,, Graham 2500 Nasworthy 1600 l_a l Oak Creek 2300 l 16 7

Trindad 750 18 19 20 21 22 23 24

1 l

1 REFERENCES 2 1. Texas Parks & Wildlife Magazine, 1966. Lake Colorado City - Old Muddy. 24(8): 3-4. Texas Parks &

3 Wildlife Department, Austin, Texas.

4 2. Ibid. 1974. Try Old Muddy - Lake Colorado City.

2 (32(3): 24-27. .

3. Ibid. 1979. Calaveras Proclaimed King of Bass 6 Tournament Lakes. 37(3): 21.

7 4. Brungs, William A. 1977. General Considerations Concerning the Toxicity of Aquatic Life of Chlorinated 8 Condenser Effluent. In, Jensen, L. D., Biofouling Control Procedures, Technology and Ecological Effects. Marcel 9 Dekker, Inc. N. Y. pg. 109-113.

10 5. Battelle, Pacific Northwest Laboratories, 1979. -

Synthesis and Analysis of Ecological Information From Cooling 11 Impoundments. Volume 1. Prepared for: Electric Power Research Institute, Palo Alto, California, 101 pp.

12

6. Price, P. T., 1974. Review of Phytoplankton 13 Studies Conducted on Five Texas Reservoirs. Prepared by:

Espey, Huston and Associates, Inc. Austin, Texas for: Texas 14 Electric Service Company, Fort Worth, Texas. 32 pp.

15 7. Dames & Moore, Inc., Brazos River Heavy Metal Bioaccumulation Field Study, Allens Creek Nuclear Generating 16 Station, for Houston Lighting & Power Company, 1978.

17 8. Young, J. S., 1974. Menhaden and Power Plants - A Growing Concern. Marine Fisheries Review. 36(10): 19-23.

18 19 DE:7:J 20 21 22 23 24 l

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